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	GR No. 180559 2016-01-20	ANECITA GREGORIO v. MARIA CRISOLOGO VDA. DE CULIG JARDELEZA, J.
The case of Vda. de Panaligan v. Court of Appeals[35] further clarified that tender of payment of the repurchase price is not among the requisites, and thus unnecessary for redemption under the Public Land Act. Citing Philippine National Bank v. De los Reyes,[36] we ruled that it is not even necessary for the preservation of the right of redemption to make an offer to redeem or tender of payment of purchase price within five years. The filing of an action to redeem within that period is equivalent to a formal offer to redeem, and that there is even no need for consignation of the redemption price.[37] Thus, even in the case before us, it is immaterial that the repurchase price was not deposited with the Clerk of Court.
	GR No. 204672 2015-02-18	SPS. RODOLFO AND MARCELINA GUEVARRA v. COMMONER LENDING CORPORATION PERLAS-BERNABE, J.
In this relation, it is apt to clarify that contrary to TCLC's claim,[45] the tender of the repurchase price is not necessary for the preservation of the right of repurchase, because the filing of a judicial action for such purpose within the five-year period under Section 119 of the Public Land Act is already equivalent to a formal offer to redeem. On this premise, consignation of the redemption price is equally unnecessary.[46]